American Mortgage Corp. v. Hope

675 A.2d 912, 41 Conn. App. 324, 1996 Conn. App. LEXIS 234
CourtConnecticut Appellate Court
DecidedMay 14, 1996
Docket13604
StatusPublished
Cited by2 cases

This text of 675 A.2d 912 (American Mortgage Corp. v. Hope) is published on Counsel Stack Legal Research, covering Connecticut Appellate Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
American Mortgage Corp. v. Hope, 675 A.2d 912, 41 Conn. App. 324, 1996 Conn. App. LEXIS 234 (Colo. Ct. App. 1996).

Opinion

SPEAR, J.

The principal issue in this case is whether, in determining the amount of the defendant mortgagor’s debt for inclusion in his bankruptcy plan under Chapter 13 of the United States Bankruptcy Code, 11 U.S.C. § 1301 et seq., the trial court should have included, as [326]*326part of the debt, certain expenses incurred by the plaintiff second mortgagee after title vested in it pursuant to a judgment of strict foreclosure. Those claimed expenses are the realtor’s commission on the sale of the property, conveyance taxes, and recording fees (sale expenses) as well as interest on the first mortgage from the payoff date through the date on which the plaintiff sold the foreclosed property (interest expense). The second issue is whether the trial court improperly refused to award additional attorney’s fees that the plaintiff claims it incurred because of the bankruptcy proceedings.

The plaintiff appeals from that part of the judgment disallowing the sale expenses and additional attorney’s fees and the defendant cross appeals from that part of the judgment allowing the interest expense. We affirm the trial court’s judgment with respect to the sale expenses and the denial of additional attorney’s fees. We reverse the judgment with respect to the interest expense.

There is no dispute as to the relevant facts. On April 4, 1990, the defendant executed a promissory note in the amount of $30,000 payable to the plaintiff and secured by second mortgages on two separate parcels located in Berlin and New Britain respectively. Upon default in payment, the plaintiff commenced separate foreclosure actions on the properties. The court rendered a judgment of strict foreclosure as to the Berlin property and title vested in the plaintiff on November 2, 1991. On December 17, 1991, the plaintiff paid off the first mortgage. On February 13, 1992, the plaintiff sold the Berlin property for $109,900. The court rendered a judgment of foreclosure by sale in the New Britain action, but the sale was stayed because the defendant filed a petition in bankruptcy on November 16, 1991.

[327]*327In the bankruptcy court, the defendant agreed to pay the amount that the Superior Court found to be due to the plaintiff. The bankruptcy court ordered a relief from stay in the New Britain foreclosure “for the limited purpose of determining the debt due [the plaintiff] for inclusion in the debtor’s chapter 13 plan.” In finding the debt, the trial court disallowed the realtor’s sale commission in the amount of $6594, recording fees and conveyance taxes of $680.39, as well as the plaintiffs request for additional attorney’s fees. The court did allow interest in the amount of $2009.12, computed from the date on which the plaintiff paid off the first mortgage to the date on which the plaintiff sold the property.

The proceeding in the Superior Court, pursuant to the relief from stay, was not a deficiency judgment hearing pursuant to General Statutes § 49-14.1 The trial court fashioned a mechanism to determine the amount of the debt pursuant to the relief from stay order. That mechanism utilized the deficiency formula of § 49-14 with respect to the sale expenses, but not the interest expense. The parties disagree as to whether the fair market value of the property should be reduced by the sale and interest expenses, before applying that value toward the debt. The defendant advocates incorporating the deficiency formula of § 49-14 so that the full fair market value of the property would be credited [328]*328toward the debt with that value being reduced by only the amount of the first mortgage and back taxes. The plaintiff asserts that, in addition to the balance on the first mortgage, its expenses relating to the sale as well as the interest on the first mortgage payoff should be deducted from the fair market value of the property and the resulting net value applied toward the debt. The trial court, in allowing the interest expense, but disallowing the sale expenses, calculated the debt to be $9228.68.

The plaintiff argues that the trial court should have adopted the procedure set out in the Uniform Commercial Code, General Statutes § 42a-9-504,2 that allows a creditor to deduct expenses and to apply the net value of the collateral toward the debt. The fallacy in this argument is that § 42a-9-504 governs a situation where a secured party takes possession of collateral after a default, but does not take title. The secured party claiming the benefit of § 42a-9-504 does not own the collateral at the time of sale, but possesses it only for the purpose of the sale and the consequent satisfaction of the debt in whole or in part. If the secured party wants to become the owner of the collateral, the procedure in General [329]*329Statutes § 42a-9-505 (2)3 must be followed. Even then, the secured party cannot obtain title if there is a timely objection. The plaintiff points to nothing in the Uniform Commercial Code that would allow a secured party, who takes title to the collateral, to sell it thereafter and to add the expenses of the sale to the obligor’s debt.

We agree with the defendant that the deficiency judgment formula is properly used in determining the amount of the debt in this situation. “ [Foreclosure is peculiarly an equitable action, and the court may entertain such questions as are necessary to be determined in order that complete justice may be done.” (Internal quotation marks omitted.) Federal Deposit Ins. Corp. v. Hillcrest Associates, 233 Conn. 153, 170-71, 659 A.2d 138 (1995). “[T]he determination of what equity requires in a particular case, the balancing of the equities, is a matter for the discretion of the trial court.” (Internal quotation marks omitted.) Federal Deposit Ins. Corp. v. Bombero, 37 Conn. App. 764, 773, 657 A.2d 668, cert. granted, 234 Conn. 908, 659 A.2d 1208 (1995). The formula in § 49-14 accurately determines the remaining debt after a strict foreclosure and it is fair and equitable to apply it here. Pursuant to § 49-14, the value of the property foreclosed is fixed as of the date title vests in [330]*330the foreclosing plaintiff for purposes of any deficiency.4 Eichman v. J & J Building Co., 216 Conn. 443, 445, 582 A.2d 182 (1990); Farmers & Mechanics Savings Bank v. Durham Realty, Inc., 34 Conn. App. 204, 207, 640 A.2d 1017 (1994). The value of the property is reduced by any prior encumbrances and back taxes. “Although § 49-14 is silent as to the deduction of prior encumbrances from the appraised value, it is well settled that the court should deduct from the amount of the appraisal the aggregate of prior claims against the property in order to determine the value of the security and hence the extent to which the debt or obligation has been satisfied by the application to it of the foreclosed property.” (Emphasis added.) Hartford Federal Savings & Loan Assn. v. Lenczyk, 153 Conn.

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Bluebook (online)
675 A.2d 912, 41 Conn. App. 324, 1996 Conn. App. LEXIS 234, Counsel Stack Legal Research, https://law.counselstack.com/opinion/american-mortgage-corp-v-hope-connappct-1996.